Cable operators continue to have concerns over the impact of
the transition of incumbent local exchange carriers to IP delivery on
In comments on various pilot program proposals -- AT&T's
geographic trial proposal in particular -- cable operators large and small were
unwilling to endorse them without more information.
In its comments, ACA made it clear that it was opposed to
the AT&T test in particular, and any others to the degree that they
compromised the "bedrock principle" that interconnection protections
apply "regardless of technology."
Given the LEC's market power, says ACA, that it must
continue to be able to rely on interconnection needs no testing and the FCC
should make it clear from the outset that interconnection mandates that apply
to traditional service will apply to IP delivery.
"In short, when dealing with these larger ILECs, cable
operators providing managed VoIP service are at a disadvantage in negotiating
reasonable and competitive rates and terms. ACA members already have
experienced problems when seeking IP interconnection with ILECs," said ACA
president Matt Polka. "Given this background, questions about the need for
the interconnection provisions of the Act to apply to VoIP service do not lend
themselves to trials."
The National Cable and Telecommunications Association said
it supported trials, at least in theory, but that it did not have enough
information on them. "At this stage of the proceeding, in the absence of
any proposal that includes details regarding a trial (such as where it is
taking place, precisely what will be tested, and how the test environment will
differ from the status quo), it is difficult for cable operators to offer much
input in response."
NCTA was not as definitive on the interconnection issue, but
definitely was raising a yellow flag. "Over many years, through the
process established pursuant to the 1996 Act, incumbents and competitors
generally have developed relatively stable arrangements governing the
interconnection of networks and the exchange of voice traffic. Any proposal
that would unduly jeopardize the stability of those arrangements -- from an
operational perspective or a financial perspective -- is likely to be cause for
NCTA said that cable ops and others affected by the LEC's
transition need to be able to review details of any proposals and have a seat
at the table at any process for developing or implementing any trials,
geographic or otherwise -- the FCC has also sought input on next-gen 911 and
the replacement of wireline with wireless services.
Obviously, cable operators could be at a
competitive disadvantage if LEC's did not have to offer them interconnection to
their new IP networks on reasonable rates and terms, as FCC rules require of
traditional voice service.